At least that was the nominal purpose of the event. In reality it was a celebration of sustainability done right and, indeed, a celebration of the value of being the “man in the arena” and testimony to the fact that in doing the work that needs to be done, one can be offered opportunities undreamt of and often obscured by an unknowable future.

This was a big project, an almost ten-million-dollar technological marvel that takes most of the waste generated from peeling onions and uses it to generate electricity. Significantly the waste is not burned but, instead, mostly converted to onion juice which is then converted into methane gas which, after conditioning, is used to generate electricity in high-efficiency fuel cells.

It is a marvel to behold, and the technical wizardry attracted most of the attention, but the truth is that what Gills Onions provided is an example for the industry, indeed an example for the world, not just of a scientific and engineering achievement but also, and with more long term significance, a model path by which companies ought to engage with sustainability.

Anaerobic digester — utilizes a series of processes in which microorganisms in the absence of oxygen break down onion waste and produce a methane- and carbon dioxide-rich biogas suitable for energy production.

Fuel Cell Stack Module is the centerpiece of the power plant and is comprised of multiple fuel cells operating in parallel. Hydrogen is internally reformed for the source fuel to support the NON COMBUSTION electrochemical reaction in the fuel cell. Fuel is combined with oxygen from air to produce energy. Ultra clean electrical power, in the form of direct current (DC), and heat are produced in the process.

Most of the time, producers get involved in sustainability somewhat reluctantly, often pushed into sustainability by a customer. The process becomes very negative, constantly focused on doing less of a bad thing at the behest of outsiders.

Yet all one had to do at this event was listen to Nikki Rodoni (see photo left) — Gills’ longtime Sustainability Coordinator and daughter of Steve Gill, who won her “Director” spurs with this new project — and one realized that Gills had walked a different path.

Nikki was beaming, as was her father, her Uncle, David Gill, her sister, Nelia Alamo, as was the whole Gill family and the whole team of associates at Gills Onions. This was because they didn’t do this energy project under duress; they did it because it was so compelling. In that singular fact, one saw that sustainability, done well, can drive an organization to new heights of achievement.

Of course, seizing compelling opportunities is in the DNA of Gills Onions. Here is how they explain the founding of the company and its connection to this new waste disposal solution:

“Disposing of onion waste, one of the biggest challenges Gills Onions faces today, is ironically one of the major reasons why the company began 25 years ago.

La Victoria Salsa approached David and Steven Gill, who were growing peppers for the popular salsa brand, and asked if they could provide whole onions that were already peeled. At the time La Victoria was using dehydrated onions and always wanted to use fresh. They didn’t want to deal with peeling the onions and managing the waste. La Victoria’s problem became Gills’ opportunity and Gills Onions was launched. Since then Gills has grown into the nation’s largest fresh-cut onion processor. Its waste has grown along with it; up to 300,000 lbs. of waste per day.”

Coordinating the project was quite a task. There was a roster of technical innovations — after all, nobody actually knew much about the properties of “onion gas” — but the financial wizardry necessary to make the project viable was no less impressive.

This was a pioneering project and a roster of programs have been created to make it feasible for companies to pioneer new technology. Gills was able to secure a check from Southern California Gas “Self-Generation Incentive Program” for $2.7 million (see photo above). The California Energy Commission gave a grant for $499,000, and Gills can access a $1.8 million investment tax credit. This reduced the effective cost of the project from $9.5 million to $4,501,000.

With annual savings from the project estimated at $700,000 in electricity and $400,000 that would have otherwise been paid to dispose of the waste in the fields, the project should provide an annual return on investment in excess of 20%. — although only time will tell what the time frame will be under which such a set-up needs to be depreciated. This calculation also assumes a company pays enough taxes to use the investment tax credit.

Steve Gill andCalifornia Secretary of Agriculture,A.G. Kawamura

Equally important, the project substantially reduces uncertainty for Gills. Issues such as what will electricity cost in the future and whether there will be restrictions on how Gills can dispose of waste in the fields are no longer variables to the same extent they were before.

There are plans for the future. Currently about 25% of the onion waste is compressed, chopped and sold as high value cattle feed while the other 75% is onion juice and goes to make the biogas and, ultimately, the electricity. Future plans include getting into the neutraceutical business by extracting the polyphenols and selling these as anti-oxidant supplements for humans. Efforts are also planned to reuse water and to store energy so it can be used when needed.

It is easy to get wowed by the technology and, in fact, some believe that small fuel cells may one day fuel everything from cars to individual homes and businesses. Still, it is unlikely that most produce companies need their own Advanced Energy Recovery System. This is, however, beside the point.

Every company has to face its own challenges, grasp its own opportunities, build its own future.

There is much to learn from the entrepreneurial attitude that prevails at Gills Onions, from accepting a client’s challenge to peel onions, to building this energy marvel. This is an organization that seizes opportunities and understands that sustainability, properly understood, is not about stasis; it is about progress.

It is a thought process that is an example for us all.

Many thanks to Steven and David Gill and all the folks at Gills Onions for laying out a path that many will come to follow. Sharing so much, so publicly, is a service to the industry… and the world.

We’ve written plenty about the locally grown movement and about sustainability, so when we heard that a battle was brewing in Britain between advocates of eating seasonably and the fruit and vegetable industry, we wanted to learn more. After all, isn’t all produce seasonal somewhere? Besides, our great-grandparents ate seasonably — mostly root vegetables all winter or things that were canned or preserved. Is it really true that advocates want people to go “back to the future” and give up bananas, pineapples, mangos, papayas, etc.?

We asked Pundit Investigator and Special Projects Editor Mira Slott to find out more:

Q: Could you describe and put into context how this seasonal campaign got started and the various groups sponsoring it, so we can better grasp the scope of this?

A: You’ve seen our press release responding to this program. The Eat Seasonably campaign is one of a number that have come to the floor in recent months in the UK, precipitated and encouraged by the current recession, and also increasing consumer interest with sustainability and food security in the UK.

What you do have is a situation where there are some groups that have a very clear view of what they think consumers should be doing in terms of enjoying fresh produce, and giving clear guidance of what they think is appropriate. But it is a much broader alliance. It’s not just about fresh produce; it’s about being responsible in a number of ways, related to energy and travel and all those sorts of things.

Q: I understand that several seemingly disparate organizations peripheral to the produce industry have thrown weight behind this campaign to focus on locally grown UK fruits and vegetables. Where did this “eat seasonably” concept originate? Is it being pushed forward through private organizations promoting various interests that intersect, is it supported at government levels …?

A: I’m actually trying to recall the roundabout way it unfolded. The National Trust, which owns a lot of agricultural land, extended its interests, starting a non-profit initiative called, We Will if You Will.

Eat Seasonably is the first campaign from the project spearheaded by Dame Fiona Reynolds, Director General of the National Trust, and Ian Cheshire, Chairman of B&Q, a do-it-yourself store. B&Q has a planting and seeds division and encourages UK consumers to focus on growing their own fruits and vegetables. The campaign is partially funded by UK’s Department of Environment, Food and Rural Affairs (Defra), a group that wants conservation of energy in the home, in transportation, etc., and sees eating locally as an off shoot.

Promoters of the initiative say it “aims to deliver a series of new and unique collaborative efforts between business and civil society to encourage the mass mobilization of individuals toward more sustainable lifestyles.” We believe this Eat Seasonably campaign is operating on a narrow/distorted definition.

We felt it necessary to raise the flag for imported produce. It is important for Defra to expand its definition of “in-season” produce to include produce from around the world, which is “in-season” at different times of the year. The campaign is partially funded on a narrow definition of what constitutes in-season produce.

The campaign is great to encourage consumption of fresh fruit and vegetables, but we want to stop the distorted messages around it. Our industry is taking a much broader approach to promoting produce. On our website, you can examine the diverse range of programs.

Q: Could you elaborate on what is problematic with this campaign?

A: Our broad position — we take the fundamental view that it is important to encourage people to enjoy eating fresh produce regardless of its source or origin, especially to help developing countries. Our eating habits are not their best. Consumers average 2.5 portions of produce a day, whereas the target is around 5, and we have a strong interest in addressing problems of obesity, diabetes and other general health issues as an industry.

One of the reasons for our Eat-in-Colour campaign is to introduce people to eating and enjoying more fresh produce. Among a number of initiatives within that campaign, one very successful one may be of interest in the U.S. Three years running, the Healthy Eating Badge rewards young children for designing and cooking healthy meals incorporating various themes throughout the year. Finding ways to engage young people is critical to increasing produce consumption.

From a government view, 5-a-Day is a government-owned initiative, but like many things, it’s been more successful in promoting awareness of what people should be doing, but has been less successful in altering what people are actually doing. Our role is to find practical and enjoyable ways for people to actually eat their 5-a-Day. We need to go beyond just being aware of it.

Q: In that respect, have you conducted studies to track and measure the impact of these campaigns? How do you weigh where to invest resources, or for that matter whether this new Eat Seasonably campaign is worth worrying about. Perhaps the public relations effort will just lift enthusiasm for eating fresh produce and create a rippling effect to increase consumption across the board? In the U.S., there is much discussion right now on the merits of a generic produce marketing initiative.

A: We do in fact have rather detailed consumer analysis information to track human habits of eating fresh produce, and the results have been positive. Obviously what I can’t say is this is solely due to the Eating-in-Colour campaign. What I can say is that it is consummate of many other business campaigns as well. In these situations, we’re first talking about running a generic industry campaign, not promoting from a particular source, but talking about industry as a whole. We’re not able to assess whether avocado sales have increased this month because of it.

In reality, the responsibility of the industry is to introduce and encourage consumers to enjoy all fresh produce. If we don’t, our competitors, which are manufacturers of all sorts of food ingredients, will win out due to much greater marketing and promotional budgets.

Our core view is we accept the Eating Seasonably campaign encourages consumption of fresh produce. What we’re concerned about is limiting that choice of enjoyment, because it only permits British produce, and only certain produce at different times of the British season. The UK enjoys a varied diet of fresh produce, and around 60 percent of fresh produce in the UK is imported. Broadly, the UK is considerably more self sufficient in vegetables than fruit. I’d say roughly 77 percent vegetables compared to 10 to 15 percent fruit.

Our climate allows us to produce certain vegetables very well, and a number of fruit items well; if you take strawberries and apples, we produce quite a significant portion of our consumption requirements. But the climate is what the climate is in the UK. As you know, we get quite a bit of rain. Producing items such as bananas and citrus are almost impossible.

Q: How long has this seasonal campaign been running, and are you noticing any difference in terms of ways consumers are purchasing?

A: Up to date, no. The Eat Seasonally campaign was only marketed in June of this year, so we’ve responded very quickly and robustly with the press release you’ve seen and from a number of different angles. Number one, we’ve talked about the desire and interest of consumers to get produce for much longer times of the year. Actually quite often there are a lot of fruits and vegetables coming from other parts of the world that are not detrimental from a sustainability perspective.

Q: I’m hoping you could elaborate on that. Eating locally produced food has become a popular phenomenon, exemplified acutely when major UK supermarkets started differentiating food packages from Kenya with airplane stickers. Some characterize sustainability as being made up of three silos — environmental, social and business related. And all three need to be taken into consideration and balanced for true sustainability efforts. We’ve written about misconceptions regarding food miles. What is your position in this regard?

A: Food security and sustainability is a major topic in the UK for food supplies in general from meat products to cereals through to fruits and vegetables. As you’ve already highlighted, we’ve chosen to import a wide variety of fresh produce. In a country that imports large amounts of fresh produce, it gets on the radar very quickly. There are two elements we are all looking at, and the UK government is looking at how we can encourage improved food security, what is the potential of growing more fresh produce in the UK, but balancing that, we are also very aware food security is a global position, and quite rightly accept locally in-season produce grown where ever in the world, and which is enjoyed everywhere in the world. Enjoying fresh produce in season regardless of its origin is the important thing.

If you store UK produce or import from other places in Europe or from other parts of the world, one could challenge which is more efficient from a carbon footprint point of view. It may be more sustainable to import produce from Kenya, for example, than to store domestic produce in the UK.

Q: To your point, a study by Cranfield University in the UK did a comparative analysis of the impact of carbon emissions for roses produced and exported from Kenya versus the Netherlands. It found that Kenyan exports including airfreight were actually six times more carbon efficient than by the Netherlands-grown process, and the heating requirements of putting product in greenhouses. The study was commissioned by World Flowers.

A: It’s a very complex process. We need to insure that consumers do appreciate the complexities of the industry. Round about a year ago, there were consultations in the UK on whether products certified as organic should be allowed to be shipped by plane because of the air miles. We had a very avid response. Our headline position was successful on behalf of the industry. We argued the case that this was not a responsible position for a combination of reasons. First of all, from a trading position, African nations had great ability and it was important in promoting trade, and second it supported the family farms and better standards of living and infrastructure for the people of Kenya and other countries in need. [Editor’s note: read more on FPC’s response here, here and here.]

We were very actively arguing the imperative of putting into context the climate change issue. If we look at the overall supply and planes bringing those goods to the UK, well over 60 percent of those planes were passenger planes anyway, with people traveling on holiday. And even if you did include the products, the carbon footprints of journey were a small fraction of one percent of the total UK carbon footprint.

If we look at it from another perspective, in Kenya the average carbon footprint for the individual is something like one or two percent per year; in the UK it is 10, and in America I’m sorry to say it’s probably nearer 20. I think I raised that for this reason. We’re saying look, yes, we need to consider how we can be more responsible, but actually the western developed countries need to look at themselves much more closely. Preventing that trade and preventing that support would change the carbon footprint very little but would have the potential to destroy these families’ livelihood in those developing countries. Also, it would do vey little to change the carbon footprint of the UK or the world in general.

From an agricultural point of view or a carbon footprint point of view, growing of those crops is some 50 to 55 percent of its total product carbon footprint. The carbon footprint includes the growing process, but then there’s the distribution and retail side. The distribution is around 10 or 12 percent of that carbon footprint. What we’re really saying is yes the process needs to be sustainable, and that’s also about water sources and many other things. There needs to be a clear and detailed evaluation that everyone agrees to, of what that includes.

In the future, water availability will be a big issue, not just carbon footprints. It could mean looking at the impact of replacing meat-type products with produce. When you look at the produce industry, it makes up about 2.5 or 3 percent of UK gas emissions total, and if you look at meat production total, it’s about 3 times that. One of the challenges considered now and being debated is should we promote eating less meat. Changing people’s diet could result in a much more positive impact on the climate.

Q: Do you have studies in this area we could link our readers to?

A: I’m afraid these studies are quite tedious and thousands of pages, when there are probably only a few paragraphs you’d be interested in. What I could do is answer your readers’ individual questions. Tell them they are free to contact me and I would be happy to help in anyway I can.

Q: That’s an interesting proposition. Perhaps switch over from the Eat Seasonably campaign to an Eat More Produce and Less Meat campaign!

A: That would be a great idea from our point of view. From our point of view, changing people’s diet and eating less meat in favor of more produce would have a much more positive impact than people choosing to grow more produce locally.

Q: It also would be interesting to get your feedback on differing claims related to the value and health aspects of eating organic versus conventionally grown, on differences in products labeled natural or pesticide free, etc. Issues with pesticides seem to matter more to European consumers than to those in the U.S. And we haven’t even touched on food safety concerns yet!

A: From our point of view, we continue to state, and so does the UK government, that there are no proven differences in health benefits of consuming fresh conventional versus organically grown produce. The clear government view at the moment is that eating fresh produce, regardless of its origin, is good for you, not the fact that it happens to be local or it happens to be organic.

Q: There is some blurring there, that some consumers might think it’s better if it’s locally grown, and also from a food safety standard as well.

A: The UK overall, has very rigorous standards in food safety and hygiene requirements. Our issues in terms of food scares are very, very rare with fresh produce. In the UK, produce accounts for an exceptionally few number of health-related issues. It tends to be other food products like meat connected to food safety problems in the UK.

Q: Alas, food safety has become an all-consuming issue for the produce industry in the United States. Although numerous variables come into play when assessing the problems, many U.S. industry executives have looked to the stringent British retail food safety standards as guidance.

A: Pesticides are an issue for consumers in the UK and throughout the EU. We do produce a number of guides on the responsible use of pesticides, and other food safety guidelines. I’m not saying you don’t do that in the U.S., but we’ve worked very hard to get that message out there and have been very successful in achieving compliance.

Q: You mention some cultural differences with consumer sensitivity toward pesticide use. Irradiation has become a more poignant issue in confronting food outbreaks. And use of GMO’s could influence food security. Could you share your views on these topics?

A: In terms of irradiation, products that have been irradiated are not acceptable in the UK and Europe. They are banned and there is no consumer debate. It just doesn’t happen. There is also significant industry customer, and more important, consumer resistance to eating GMO foods, as opposed to the U.S.

I do think as the months and years go on, with the population growing rapidly in the UK and the world, there will be a real challenge as it relates to food security and sustainability — how can we responsibly increase the amount of food without being allowed to consider responsible use of new technologies? We have a very robust and rigorous system of control with chemicals. There is legislation on how some pesticides will be allowed to be used in the future. That said, we are certainly concerned as an industry and need the appropriate technology to provide produce at prices consumers can pay.

There is certain keen interest in organics, but it is a small proportion of the total market, two or three percent, and it’s sold at a premium. From an agronomic standpoint, looking at food security, we simply can’t produce the needed amount of food in that way.

Q: Some of these issues — use of pesticides and GMOs, sustainability, food safety, etc. — can be overlapping or contradictory…

A: It does become quite complicated doesn’t it? Different elements of society choose to buy organically or locally or buy free-range if talking about meat-based products for a whole host of reasons; quite often it may not be for taste or flavor. It may be for many other reasons.

Q: Isn’t that even more reason it’s important to get accurate information out there so consumers can make intelligent decisions based on the facts?

A: There are organizations that monitor what pesticides can and cannot be used in the U.K. or on products exported to the U.K. There are very rare occasions when issues arise, but almost 98 percent of the time Good Agricultural Practices are being used. Consumer evaluation panels show concern of pesticides declining and an increasing understanding the industry is responsible and is doing what government expects of them.

We do a great deal in terms of promoting best practice and providing education on what people should be doing with agricultural products. With organics, the language of ‘my products are pesticide-free’ tends to be great marketing strategy, but as you know, saying the product is organic does not mean that pesticides have not been used. That is something that is often a misplaced assumption by many consumers.

Q: We’ve covered many topics since pivoting off of the Eat Seasonably campaign. Are retailers gravitating to this campaign? Will they be marketing the concept with signage and promotions?

A: From our point view, what we’re looking to do is to encourage consumers to eat more fresh produce, so regardless of the season, the great news is that retailers and others are promoting fresh produce. If it’s UK strawberries and they’re in season, and they’re introducing consumers to a product they will enjoy, that’s great. It’s all about balance, enjoying product regardless of what UK product is in season. For some it could be UK strawberries. We just don’t want that to be at the expense of other great produce.

Q: I know you were quick in putting out this press release expressing your reservations and concerns about the Eat Seasonably campaign. Are you taking any other actions at this juncture?

A: The overall debate of food security and sustainability is something we work on avidly with a large range of organizations in the UK and embassies around the world and retailers and the supply chain as a whole, looking to promote that constructive and balanced message.

Q: Are there retailers you can point to that are doing an exceptional job in this area?

A: You’re putting me on the spot as we have many members at the FPC. To pick one out I don’t think would do my career prospects much good! I can say that we have four or five major retailers in the UK and they’re all doing well in promoting their own position and have different views on what their consumers want nationally, in regional and local markets and in many other regards.

Q: You’re very diplomatic!

A: We also run an event called Re:Fresh, which is a conference during the day with awards in the evening. Some of the awards are geared towards retail. The big retail award at this year’s conference in May went to the Co-operative Group. They’ve become a very well-established organization. They were a smaller retailer, but recently bought Somerfield, and overnight became the fifth biggest retailer in the UK. It’s a national business looking to do things locally, via neighborhood stores.

The award is based on a number of criteria, and we were impressed by their commitment of working closely with produce suppliers, the total footprint of their stores, and their dedication to service and meeting the needs of their customers.

Q: We’ve covered much ground in this interview. What are your closing thoughts?

A: The Fresh Produce Consortium is the UK’s fresh produce association, so the members we represent would be the whole supply chain, the fruit and vegetable sector, some 900 members — importers, foodservice providers, wholesalers, packers, and many retailers including the major retailers. At the same time, we have associate members that include embassies around the world.

We have two primary aims really. One is to promote the industry in general terms and encourage and promote increased consumption of fresh produce. We also spend a great deal of our time lobbying government and other stakeholders in regard to legislation and other issues.

Q: As a single entity, your organization represents a wide scope of issues and interests.

A: Yes, the industry is very, very broad.

Q: What reaction have you received from your broad constituency since you voiced your concerns regarding the Eat Seasonably campaign?

A: The response we’ve had from all areas of the supply chain supports the importance of taking a constructive and balanced way forward. It’s about promoting increased consumption of fresh produce and it’s not about promoting one particular commodity or origin.

We had the pleasure of dining with Nigel and some of his associates at the Fresh Produce Consortium when we had flown to London to speak at the Re:Fresh conference. Nigel gets more than a few kudos for keeping a very diverse membership feeling generally happy and well attended to — without the kind of resources that the national US trade associations have to employ in that kind of task.

Here they have taken on the yeoman’s task of stating the obvious: That it makes no sense to advocate for changes in behavior for which there is no evidence that any benefit will be derived if the behavior does change.

One only has to spend a short time in the UK and one learns that sustainability and food miles are used as protectionist weapons and that consumers see sustainability as an outlet for nationalist sentiment.

We did some focus groups on sustainability in the UK and when we did them in the south of England, we found consumers waxing poetic about “local” and the need to limit “food miles.” The consumers were, by American standards, remarkably sophisticated. They understood “carbon footprints” and “food miles”… they recognized difficulties in the concepts such as the location of retail distribution centers and they all claimed to want local produce.

When we played the “dumb American” and stopped the groups in order to try to summarize our learning up to that point, we got wide agreement that most wanted to “buy local” and “reduce food miles” in order to reduce the “carbon footprint” of what they ate. Yet when we asked next if this meant that they would be thrilled to see a lot more produce from the north of France, just a short ways over the English channel, in their stores and on their plates — the groups rose, as if in unison, to explain that no, that wasn’t what they meant at all.

It quickly became obvious that these consumers had a peculiar definition of “local” and, despite their protestations as to the importance of buying local, they vastly preferred produce from the hinterlands of Scotland 800 miles away to French produce from 20 miles away over the English Channel. In other words, to British consumers the “local” movement and British nationalism are closely intertwined.

An “eat seasonably” campaign is pretty easy for forces in the UK to launch as Britain exports very little produce. So you have British nationalism, overlapping with protectionist forces and the most mindless kind of sustainability ethos that demands no evidence or proof but simply like to do things to “feel good” and you have a recipe for a mess, which is pretty much what this “eat seasonably” program is.

These things are so complicated on so many levels. Nigel’s first line of defense is very similar to the long-time point in discussions of organic: Whether in fact there ultimately will be found some health benefits to consuming organic produce is irrelevant compared to the overwhelming body of evidence that diets composed of high percentages of fruits and vegetables are healthier diets. In fact promoting organic, with its higher price points, could well lead to consumption of less healthy diets as people might eat fewer fruits and vegetables.

Equally, as Nigel points out, whatever benefits might be found to be incurred as a result of eating locally, these benefits are likely to pale before the advantages realized through a diet rich in fruits and vegetables. A strictly “local” and “seasonable” diet, with highly restricted availability and selection is likely to lead to lower produce consumption with all the health-related issues implied.

Of course, it goes beyond health. If consumers are not happy with their selection of fresh produce, they may eat more processed foods or meats — and who says that will be more sustainable?

Of course, advising people to eat local and seasonal on sustainability grounds is more an ideology than a scientific standard. The use of water, the output of carbon and other concerns vary substantially based on where and under what conditions the product is grown and transported.

If the lamb in one place is local but is fed feed that is raised by farmers with tractors, and an alternative is importing lamb from a place where the lambs graze outdoors on natural pasture, simply noting that one product is local and one has some food miles doesn’t reveal anything definitive about the relative carbon footprints on those products. It also tells you little about the totality of sustainability, encompassing the full range of environmental concerns, social concerns and economic concerns, or whether the locally grown product is actually superior.

Nigel also points out that defining what is seasonable is not so easy. In an age when controlled atmosphere storage can extend shelf-life substantially on many products, and various horticultural techniques, up to and including controlled environment agriculture, make a mockery of old seasonal limitations, it is not even clear what limits the season on many products.

We really have to give a tip of the hat to Nigel, the Fresh Produce Consortium and the British trade in general. One of the biggest problems we confront, not just in the trade but in Western Civilization, is the common desire to do things for their symbolic significance.

Just the other day, we reported on the US experience with COOL and pointed out that many, in industry, government and consumer advocacy groups, spoke in favor of this legislation. Now that the legislation is in force, nobody pays any attention to the question of whether COOL has actually achieved any of its intended purposes.

There is such a thirst among many people to “do something” to be part of making the world a better place, that, all too often, in their desire to contribute, people skip the difficult work of determining how to actually help the world and, instead, simply do things that “feel good.”

Yet if the groundwork has not been done, if the science isn’t thorough and sound, one is as likely to do harm as to do good. Certainly, the notion that we know the answer to the problem blocks a lot of serious work that could lead to a brighter future.

We thank Nigel Jenney and the Fresh Produce Consortium for helping us think through such an important issue.

Our coverage of the proposal for a Generic Produce Promotion Board has been extensive, and much has been in the form of a critique of the proposal and how it has been presented to the industry.

We don’t believe the support is there right now to pass such a program but many people, such as Mike O’ Brien from Schnucks, whose letter we published here, are passionate about the idea. We thought we would attempt to lay out a procedure by which advocates for such a program would be more likely to prevail. We titled the piece, Got Produce? Ten Steps To Creating New Dialog On Generic Promotion.

Those who oppose such plans, though, were having none of it. Here is a letter from a retailer explaining this point of view:

Great, let’s layer on another cost and disguise it as “for the greater good”.

Just one more thing that business owners would be required to deal with and pay for.

I detest the idea of mandatory anything, especially when it comes to funding something as immeasurable as a generic marketing plan. Save the mandatory for those things that can really harm someone.

For those that are passionate about the plan and want to expedite it to fruition … voluntary is a nice term!

We confess that we share his concern as to the casualness with which some have proposed such a mandatory program. We think the hurdle should be set very high.

We’ve spoken to constitutional scholars who tell us that they think the whole concept is an unconstitutional delegation of the power of Congress to tax. In litigation that reached the Supreme Court, 4 out of the 9 Justices held that such mandatory programs abridge the “freedom of speech” by compelling people to pay for messages they may find repugnant.

So, though the current Court ruling allows for such mandatory vehicles, it was a very close vote and may be decided differently in the future.

From an economic point of view, the argument for mandatory assessments is that they resolve the “free rider problem”. Basically, the idea is that there are certain things that everyone would like to do, that could be profitable for everyone — however, if done on a voluntary basis, there is a tremendous incentive to not chip in because one can get all the benefits of the activity without paying the cost.

Typically, more and more people will realize this, refuse to pay the cost and then the activity won’t be done at all.

Advertising and promotion falls into this category: If spending a percent or two of sales will increase demand, raise prices and so everyone will profit, a voluntary effort will give the benefit of the program to many who don’t pay in. Perversely, these “free riders” will be more profitable than those who do contribute. In the end, the voluntary effort will likely be disbanded or be very small.

So, if there was industry consensus, if virtually the whole industry was persuaded that this was a profitable idea, then doing it through a mandatory vehicle is a reasonable way to bind ourselves to each other and avoid the free-rider problem.

The problem, of course, is that there is no such consensus.

In fact, the efforts being conducted are not designed to build consensus. At PMA’s Foodservice Conference, for example, PMA was kind enough to set up a National Fruit & Vegetable Research & Promotion Board Town Hall” sessions to discuss the generic promotion program. These “town hall” events are really panel discussions and, as we’ve written before, not really the most effective way to hold anyone’s feet to the fire and get answers.

The odd thing about this program, however, is that the moderator of the session is none other than Mark Munger.

Now Mark, Vice President of Marketing at Andrew Williamson Fresh Produce, was also the chairman of the Produce for Better Health Foundation, while the generic plan was being developed. Mark has been one of the plan’s primary advocates traveling to association meetings to advocate on behalf of the plan.

Now we know Mark and, as we wrote here, we like Mark and we are sure he will try and be fair. Inherently, however, his advocacy role is in direct conflict with a moderating role.

It is like saying we are going to have a panel discussion on whether we should have health care reform and Barack Obama will be our neutral moderator. It makes people feel that the fix is in.

This is really a shame because people either ignore what they perceive to be a biased process or they throw up their defenses. It means that the opportunity to persuade is lost.

Dick McKellogg’s letter speaks to the fact that to even consider going to USDA and asking them to hold a vote is a very serious matter. In America, we typically believe in freedom and voluntary action. To override such beliefs we need substantial consensus.

This means we need a credible and fair program to educate and persuade. This process simply isn’t up to the task.

Many thanks to Dick McKellogg and Lowe’s for helping us think through such an important issue.

We’ve been writing a great deal about sprouts. As an area of the industry plagued by food safety outbreaks, we thought it important to understand and seek solutions to the problems seemingly endemic to these products. In addition, as the sprout industry has been wrestling with food safety issues longer than most of the fresh produce trade, there may well be lessons the broader industry can learn through careful study of how the sprout industry has wrestled with these difficulties.

One lesson is the importance of industry unity. The sprouting industry seems forever divided in twain… sometimes it is the large producers vs. the small guys, sometimes it is those active in the International Sprout Growers Association and those that are affiliated with Brassica Protection Products. In either case, it is difficult for an industry to wrestle with its problems when the industry is in such discord.

“With regard to seed, it is completely untrue that all the outbreaks have come from Caudill Seed Company and that none have come from Bob Rust’s ISS. By my reckoning, of the 11 recalls/market withdrawals of alfalfa sprouts in 2008 and so far in 2009, seed from Caudill was implicated in only 5, seed from others, primarily ISS, was implicated in 5, and 1 was facility-related.”

I am unaware of any outbreaks that ISS seed has been implicated in. I regret this error due to my incomplete research.

We also received a letter from Bob Rust of International Specialty Supply (ISS) dealing with the same article:

The June 23, 2009, letter by Earl Hauserman of Brassica Protection Products is interesting though terribly inaccurate. For example, it says:

“With regard to seed, it is completely untrue that all the outbreaks have come from Caudill Seed Company and that none have come from Bob Rust’s ISS.”

I suspect he is responding to a May 20th Pundit letter in which a correspondent wrote:

“Interestingly enough, it seems that out of all seed suppliers, one major supplier was responsible for most outbreaks that occurred in last 10 years.”

I contacted Mr. Hauserman and have given him ample time to retract his letter or correct his inaccuracies. He acknowledged this error in an email where he says: “I am unaware of any outbreaks or recalls that ISS seed has been implicated in. I regret this error due to my incomplete research.”

He is correct, yet he has not done so publically. Therefore, I will respond with hyperlinked references.

Mr. Hauserman also wrote: “We have had problems, but far, far fewer than the industry as a whole.”

Mr. Hauserman should have known this considering that Brassica sprout growers has been involved in all US sprout related outbreaks during the 2008-2009 period Mr. Hauserman referred to in his letter. Actually, Brassica sprout growers has been involved in all sprout-related outbreaks in the last five years. And all the seed used to produce those sprouts was, according to the sprout growers involved, supplied by Caudill Seed Company.

According to the FDA, there is also a PFGE pattern link of 20 hospitalized victims’ to a sprout-related Listeria monocytogenes recall. Although the sprouts were grown by a Brassica Sprout grower, I am not aware of seed being the suspect in any Listeria recall or outbreak to date, including this one.

Other sprout growers using Caudill seed may have played a minor role in one or more of these outbreaks. I am unaware of any other outbreaks during this time period attributed to sprouts. If there were some reported illnesses from sprouts not either associated with Brassica growers or sprouts produced from seed supplied by Caudill Seed Company, I would appreciate hearing about it.

ISS seed was implicated in a single sprout-related outbreak ten years ago, and that is why we developed the ISS Seed Screening Program. ISS seed has not been implicated in any outbreaks since.

Our seed has produced sprouts involved in a sprout recall relating to confirmed positives of Salmonella or E.coli 0157:H7. The grower was certain that our seed was not the cause. The government did not implicate our seed nor did they contact us regarding this recall. However, this was Salmonella, and we assume that if it is Salmonella or E.coli 0157:H7, there is a good chance that it did come from the seed. We brought the seed back from sprout growers and tested it again. We could not find contamination. Regardless, we took the seed off the sprouting seed market and there were no reported illnesses.

Although ISS has received accolades the world over for developing a seed safety program that has removed several contaminated lots of seed from the market, it is not likely ISS Screened Seed will always have a perfect record regarding outbreaks. We sample, sprout, and test 25 grams from each and every bag we screen. Besides testing the spent irrigation water for Salmonella and E.coli O157:H7, we also send a separate lab some of the sprouts to be homogenized and tested for Salmonella, E.coli O157:H7, Shigella, Listeria monocytogenes, and generic E.coli.

If generic E.coli is found, we test for Enterotoxigenic E. coli (ETEC). Still, there may be times when the seed is so lightly contaminated that seed sampling does not capture a pathogen in the seed. When this happens, we hope the microbiological testing by the sprout growers will discover it and our prompt communication with other sprout growers having the lot will minimize the risk.

We would never be ashamed of recalling seed anytime there is an elevated risk that it may be contaminated. A recall should not be an implication of guilt. Nor should a company consider the legal or financial ramifications of a recall. A recall is a responsible act to reduce the risk of foodborne illness.

When discussing outbreaks, one should focus on the number and severity of illnesses, not numbers of outbreaks. One outbreak involving 200 people is worse than 50 outbreaks of the same severity involving one or two people each.

Since March 2001, there appear to have been 14 reported sprout-related outbreaks in the US and Canada, involving over 1,100 reported illnesses. The average outbreak involved about 79 people. Again, none of those outbreaks or illnesses came from ISS seed.

These reportedly involve multiple outbreaks with the same PFGE pattern and multiple outbreaks of the same Phage type. They also include an outbreak in which a sprout grower told the seed supplier that his spent irrigation water had a confirmed positive, and the seed supplier never informed sprout growers using the seed of the confirmed positive. But I will save all this for later Pundits should this dialog continue.

As a member of the newly formed committee of the ISGA and FDA to improve the Sprout Guidance, I have suggested that sprout growers should have their seed suppliers sign a “communication agreement,” which obligates the seed supplier to inform them within 24 hours if there is ever a presumptive or confirmed positive on the seed lot they are using.

All of the information above is accurate to the best of my knowledge and presented to defend my company and enhance the safety of sprouted seeds. If anyone is aware of any additional information or information that is either incorrect or misleading, please let me know so I can make appropriate corrections.

It is clear that Mr.Hauserman made a mistake in his research of the matter and he has now publicly acknowledged that error.

At the same time, the significance of all this is not 100% clear. Caudill is the largest seed producer and the Brassica-affiliated producers are the largest producers of sprouts, so it is not surprising that most of the outbreaks should touch upon both organizations.

More broadly, with all the testing going on at the sprouting companies, it is unclear to what extent the recorded outbreaks reflects the contamination level of the seed.

Besides, the incidence of contamination discovered in sprouts released to consumers is so tiny that we really can’t derive any statistically valid information as to the safety of one firm’s seed vs. another’s from the outbreak statistics.

The odds of getting double zero on a roulette wheel in a Monte Carlo casino are one in 37 but that doesn’t mean it won’t show up three times in a row. And the fact that it shows up three times in a row doesn’t change the odds. And at roulette, we actually catch every double zero that shows up.

So it is that the fact that one seed company has three outbreaks in a row doesn’t tell us much, especially in light of the fact that we have very incomplete knowledge of the degree to which known outbreaks correspond to seed contamination.

In light of our limited knowledge, we think the wisest course is to follow sound practices likely to reduce the incidence of pathological contamination.

We mentioned here that Primus has been kind enough to donate its services in an experiment to grow alfalfa to be used in sprouting under conditions fit for human consumption. We asked for volunteers from retailers and those able to farm some alfalfa. We’ve secured a wonderful retail partner willing to advance the cause of food safety — and we will be unveiling its name soon.

We are still seeking a farmer to grow some alfalfa for this project. This can be either a traditional alfalfa grower looking to learn the most advanced standards in growing food for human consumption or a produce grower who is willing to set aside a few acres for alfalfa to participate in this pilot project.

There are many issues in sprout growing, but a precept of food safety is that prevention is better than remediation, and one of the known problems with alfalfa sprout production is that the seed is raised for animal use — and then diverted to human consumption. We believe that growing the seed with the same standards we would use for ready-to-eat products such as leafy greens would reduce the likelihood of contamination.

If you are a farmer willing to participate in this project and grow some alfalfa under such conditions, please let us know here. This would be a significant contribution to a safer food supply.

We thank both Earl Hauserman of Brassica Protection Products and Bob Rust of International Specialty Supply for trying to clarify these issues.

We encourage the whole sprouting supply chain to lay down the hatchet and try to work together to build a safer food supply.